https://www.taxtmi.com/caselaws?id=468130 Under the India-UK DTAA, underwriting commission and reimbursement of expenses for GDR/FCCB issue services were not taxable as fees for technical services because the investment banking and underwriting work was rendered outside India and was not made available to the Indian companies in the treaty sense. The Tribunal followed its earlier order in the same assessee's case and held that the receipt was not chargeable under section 9(1)(vii) of the Income-tax Act, 1961. The addition was therefore not sustained and the Revenue's appeal was rejected. en-us Thu, 08 Aug 2013 00:00:00 +0530 Fri, 17 Apr 2026 13:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468130 Under the India-UK DTAA, underwriting commission and reimbursement of expenses for GDR/FCCB issue services were not taxable as fees for technical services because the investment banking and underwriting work was rendered outside India and was not made available to the Indian companies in the treaty sense. The Tribunal followed its earlier order in the same assessee's case and held that the receipt was not chargeable under section 9(1)(vii) of the Income-tax Act, 1961. The addition was therefore not sustained and the Revenue's appeal was rejected. Case-Laws Income Tax Thu, 08 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468130